EPSTEIN
page 3 / 140 . OCR, unverified
Mexico 87056, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively
valued his New York townhome at $55,931,000.00. Epstein conservatively valued his New
Mexico ranch at $17,246,208.00. In addition, Epstein owned residences in the Virgin Islands,
Florida, and France, and even on his own island, Great St. James Island, where his
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 6 of 16
transcontinental sex trafficking of hundreds of young females servicing him, his co-conspirators,
and wealthy and powerful individuals around the world occurred.
25.
The allegations herein concern Epstein’s tortious acts against Plaintiff while at Epstein’s
mansion in New York, his home in Florida, his home in the Virgin Islands, his apartment in
Paris, and his New Mexico ranch.
26.
At all times material to this cause of action, Jeffrey Epstein utilized his seemingly
unlimited power, wealth, and resources, as well as his deep connections to powerful and
politically connected individuals to intimidate and manipulate his victims of sexual abuse.
27.
Epstein and his co-conspirators had perfected a scheme for manipulation and abuse of
young females. As part of the scheme, a female “recruiter” would approach a young female and
strike up a conversation in an effort to quickly learn about the young female’s background and
any vulnerabilities they could expose. The recruiter would then manipulate the young female
into coming back to one of Epstein’s residences by offering the young female something she
needed. At times the recruiter’s lure would be a modeling opportunity, money for education,
help for the young female’s family, and a whole host of other related offers depending on their
target’s situation. Once in the residence, the recruiter and Epstein would work in concert to
impress and intimidate the young female with displays of vast wealth, including having
employees that were butlers and maids formally dressed around the house. They would also
strategically place photographs of very powerful political and social figures amongst
photographs and art displaying nude females in an effort to normalize the sexual abuse. They
would also normalize the sexual abuse by placing a massage table and spa related products
around the massage area in an effort to legitimize the area where the abuse was set to occur.
Once abused, Epstein and his co-conspirators continued to manipulate the victims, using their
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financial power, promises, and threats to ensure that the victim returned as directed and remained
compliant with their demands.
B.
The Arrest, Prosecution, and Death of Epstein
28.
The sexual trafficking ring described herein started at least as early as 1995 and
continued up until at least July 2, 2019, when the U.S. Attorney’s Office for the Southern District
of New York (“SDNY”) charged Epstein with sex trafficking conspiracy and sex trafficking in
violation of 18 U.S.C. § 1591. He was arrested on July 8, 2019, pursuant to the SDNY’s Sealed
Two Count Indictment, which is attached as Exhibit A.
29.
The Indictment described Epstein’s conduct and his abuse and trafficking of females in
the same trafficking operation he used to abuse and traffic Plaintiff.
30.
Epstein’s last will and testament (the “Will”) was executed on August 8, 2019, at the
Metropolitan Correctional Center. The witnesses were Mariel Colón Miró and Gulnora Tali. The
Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an
“Oath of Willingness to Serve as Executor and Appointment of Local Counsel.”
31.
Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10,
2019.
32.
Epstein’s last will and testament was filed on August 15, 2019, in the Probate Division of
the Superior Court of the Virgin Islands.
33.
Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court
of the Virgin Islands for Epstein’s 1953 Trust on August 26, 2019. See Certificate of Trust, In
the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26,
2019).
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34.
Epstein’s will was entered into probate on September 6, 2019, and the Superior Court of
the Virgin Islands accordingly authorized Darren K. Indyke and Richard D. Kahn to administer
Epstein’s estate. See Order for Probate, In the Matter of the Estate of Jeffrey E. Epstein, Probate
No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the
Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019).
35.
The Will’s first article directs Epstein’s executors “to pay from my estate all expenses of
my last illness, my funeral and burial expenses, the administration expenses of my estate and all